Archives for January 2021

Show Notes: 

Addressing the student loan debt has taken on even greater urgency since the advent of the COVID crisis. Several stimulus proposals call for the cancelation of all or up to $50,000 of student loan debt, but would such relief help or hurt the economy?

Mark Goldwein, Senior Vice President and Senior Policy Director for the Committee for a Responsible Federal Budget (CRFB) stops by Clark Hill’s Credit Eco to Go to discuss his latest article “Canceling Student Loan Debt is Poor Economic Stimulus”. Mark acknowledges that while getting rid of debt can be helpful for debt holders, it is not the appropriate vehicle for economic stimulus. For one it does not change people’s cash flow very much and research shows that for every $1 dollar of student loan forgiveness only $.23 cents is returned to the economy.

Mark is a proponent of direct economic stimulus and offers some suggested alternatives to help student loan borrowers both in the short and long term.

[article_ad]

DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions.

Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

BRAINERD, Minn. — Tratta, a payment experience platform (PXP), officially launched as of January 2021 after a successful 6-month private beta after partnering with some of the most well-known companies in healthcare, government, financial services, telecommunications, fintech, auto finance and other various industries intersecting with accounts receivable, credit and collections. 

Tratta provides a payment experience platform that uses real-time data to improve the transaction experience across an entire organization: the business’ experience on the back end, and the customer’s experience on the front end. 

Tratta includes a unified dashboard, data enrichment, public and private APIs, a growing suite of ready to launch 3rd party applications, and prebuilt components to help create the best payment experience for customers and operators alike. Tratta’s technology and methodology have proven to reduce ACH returns from 10% of total transactions to between 1-3%, increase card approval rate to an average of 80% or greater, prevent payment plan breakage by factoring in early warning signs, and, through its BankConnect feature, clients have seen a reduction in reconciliation errors of at least 50% and shortened month-end close by 2-4 days. 

For more advanced companies that are focused on machine learning, AI and data-driven decision making, Tratta offers a vast amount of raw and enriched data that can be fed back into any system. The platform has a free trial version and no startup cost. Tratta’s subscriptions model is built to scale for operations of all sizes, from small business to enterprise-level organizations that require complex workflows, troves of data, and role level access among multiple departments. 

The platform’s vendor-agnostic approach means it doesn’t replace or interrupt any ongoing processes, fully launches in minutes, and can scale as needed instantly. Tratta has no code or IT required when starting, making it incredibly user friendly for anyone at any level of experience with technology. Tratta is accepting new clients, expanding its partnerships, and releasing new beta features on a first come first serve basis.

Tratta is a member of the iA Innovation Council and regularly seeks ways to provide new and unique solutions to the ARM industry. 

Visit tratta.io for more information.   

DEERFIELD BEACH, Fla. — Starmark Financial LLC, a national debt buyer, announced it will open its main headquarters in Deerfield Beach, Florida.   Privately owned by Brett Silver, CEO & Co-Founder and Susan Richards, President and Co-Founder, the firm expects to hire 75 FTE.  

Silver brings over 30 years of collection experience starting from working with his father at the family business, Allied Bond and Collection, then building NCB Management Services, Inc.  Brett sold his shares back to the organization in 2019 exiting the company after building it from start-up to 500 employees.

Silver built a world-class ARM organization inserting lofty principles into process and performance.  “My dedication was always to the people I hired,” he said. 

“My passion is in the people we hire, not just the interview, but the ongoing relationship over time.” 

Silver applied those same principles to his relationships with business partners building a reputation on out-servicing the competition. 

“I’m excited to partner with Susan on this new venture, having worked with her for several years.  I respect her knowledge, work ethic and dedication to the Industry. We’re a winning combination.”

Richards has been in the ARM industry for over 30 years. She started at Allied Bond and Collection as Collector working her way up and has spent the last 20 years with NCB Management Services, Inc. where she had held several positions. 

She resigned in December 2020 as NCB’s Chief Operating Officer after building a team of true professionals in the art of customer treatment.  “I believe in a culture that not only focuses on the individual, but building the best-in-class teams,” she said. 

Richards works with her management to allow them to be the best they can be. “I’m thrilled to be back working with Brett. We believe in the same principles, our people and in leadership as an honor and having people follow you as a privilege. People follow leaders that they can trust, have their back and go the extra mile.”

 Silver and Richards said they are extremely excited about launching their main headquarters in South Florida, and are looking forward to expanding their previous successes.  

Who is Starmark?

Founded in 2021 whose principals have over 60 years in the collection and debt buying Industry, Starmark’s Vision LLC ‘s core values are in its people, in the process and in their results.  

Focus is on the customer and how Starmark can best serve and deliver exceptional customer service. The Process involves taking each customer’s situation and treating it individually and listening and learning to help customers back on a path resolving their financial hardship.  Starmark results are based on its expertise in the debt buying business as it continues to lead the financial markets by creating a culture of forward thinkers, hiring talent, mastering innovation and constantly improving on our state-of-the-art training and tools to adapt to ever-changing environments.  

It’s Mission: To deliver outstanding customer service by focusing on “Best-in-class” treatment.

On October 30, 2020, the CFPB published its years-in-the-making amendment to Regulation F (“the Rules”) to implement the FDCPA. These rules address many topics, including email and text message communications, time, place and matter communication restrictions, record retention requirements, and the long-awaited solution to the infamous Foti problem  – voicemail messages. But is the CFPB’s solution to the voicemail problem really a solution for companies whose name suggests they are in the debt collection business? 

In response to overwhelming industry support for a legal fix, the CFPB offered a solution to the age-old Foti problem for debt collectors. (As a refresher, the problem is this: what can a debt collector say on a voicemail without violating the FDCPA’s requirement to provide certain disclosures to consumers while at the same time complying with the FDCPA’s prohibition on unauthorized third party disclosure in the event someone other than the consumer hears the message?) The CFPB’s solution is a newly birthed creature named the “limited content message.”  

The Rules define a “limited content message” as a voicemail message for a consumer which contains:

1. The business name for the debt collector (so long as the name does not indicate the company is in the debt collection business)
2. A request that the consumer reply to the message
3. The name of one or more natural persons whim the consumer can contact to reply to the message
4. A telephone number(s) that the consumer can use to reply to the message 

In addition, the message may include the following:

1. A salutation
2. The date and time of the message
3. Suggested dates and times for the consumer to reply to the message
4. A statement that if the consumer replies, the consumer may speak to any of the company’s representatives or associates. 

If a voicemail message left by a debt collector for a consumer contains the required items (1 through 4) and any or all of the allowed items (5 through 8) AND NOTHING ELSE, the message will not be considered a “communication” under the law and the debt collector will not be in violation of third party disclosure prohibitions if a third-party hears it or for failing to disclose that the call is from a debt collector.  To take advantage of this provision, the debt collector may not identify the consumer or reference any “account.”   

The CFPB provided sample messages as follows:

This is Robin Smith calling from ABC Inc. Please call me or Jim Johnson at 1-800-555-1212.

Hi. This is Robin Smith calling from ABC, Inc. It is 4:15 PM on Wednesday, September 1.  Please contact me or any of our representatives at 1-800-555-1212 today until 6:00 PM or any weekday from 8:00 AM to 6:00 PM Eastern time.

The limited content message sounds like a good solution, but what if your company name indicates the company is in the debt collection business? The Bureau attempts to answer this question, but falls short of appreciating the full impact of its suggestion. Recognizing the problem faced by companies whose name reveals their debt collection purpose, the Bureau suggests those debt collectors could adopt a doing-business-as name – d/b/a – which does not reveal their business function as debt collection. This sounds simple – but it is not.

Changing your company’s name or adopting a d/b/a is quite involved and would require a debt collector to change a great many aspects of their consumer-facing business. From letters, to messages, to scripting, to credit reporting, changing the corporate name or adopting a d/b/a would require the debt collector to effectively change its consumer-facing identity. In addition, doing-business-as names are required to be registered in many jurisdictions. Adopting a d/b/a also bears licensing implications. Many states which required collectors to be licensed prohibit those licensees from using a name other than the name appearing on their license to engage in regulated collection behavior. As a result, having your licensing regulator approve a d/b/a would be an additional hurdle a collector must overcome to avoid using their debt-collection-revealing corporate name. The difficulties do not end here.  

[article_ad]

How do you know if your corporate name indicates that the company is in the debt collection business?  And, by what legal standard will that question be answered? The Rules remain silent on the answers to these important questions. For most company names, applying the rule is not difficult – ABC Collection Agency, Inc., Consumer Account Collections, LLC, Debt Recovery Corporation – these names, even to the least sophisticated consumer, could reasonably indicate that the companies are in the debt collection business. At the opposite extreme, names like Zephyr, Inc., Atrium International, LLC, or Black Rock Industries Corporation convey not even the slightest indication about the nature of the business conducted by each.  But, what about names like Account Solutions, Inc., Recovery Specialists, LLC, Financial Solutions Corp.,  Credit Alliance, LLC, Creditors Protection Group, Inc.? Do these names indicate the nature of these businesses as debt collection?  Is the least sophisticated consumer the benchmark for answering this question?  The Bureau offers no answers to these difficult questions. 

Big deal – so what if a company is wrong about whether its name reveals its business as debt collection?  What are the real consequences of answering the question incorrectly? The answer to this question is clear – the message left by a debt collector whose name reveals its business as debt collection will not be considered a Limited Content Message under the Rules and will therefore not bear the protection provided by the rule to debt collectors who leave Limited Content Messages. Effectively, new rules provide no solution to the Foti problem for those debt collectors.  

In the end, debt collectors need to answer some difficult questions, not just about compliance, but about the business of leaving messages. Why leave messages at all? The answer to this question is not found in any government rule, but instead lies in the data already in the possession of every debt collector. Wise debt collectors will analyze their call data very carefully for call back rates, right party contacts, minutes spent paying high cost labor to speak to machines, and a host of other metrics to make the right business decision about whether to leave messages, including the Limited Content Message.

TREVOSE, Pa. — NCB Management Services, Inc. has hired Clement Ndegwa as NCB’s SVP of Auditing. In this role, he will lead NCB’s Auditing Department overseeing internal and external audit processes and risk assessments. Mr. Ndegwa will work closely with NCB’s General Counsel, Abigail Pressler, to develop dynamic enterprise risk management plans and high-tech control frameworks to ensure NCB maintains its reputation as an industry leader in compliance. 

Before joining NCB, Mr. Ndegwa was the head of compliance at Kinetix Trading Solutions Inc, a financial software development firm, where he led the implementation of the firm’s corporate compliance program. Prior to that he worked in the financial services industry for over 12 years in various roles including auditing, compliance, and legal.  He received his Master’s degree in law from the University of Warwick and Bachelor of Laws degree (with honors) from the University of Nairobi.

“I’m excited to be joining NCB, a forward-thinking company committed to a culture of compliance and excellence. I look forward to working with the executive team to support NCB’s commitment to high performance and integrity.” said Mr. Ndegwa.

Ms. Pressler stated, “We are thrilled to welcome Clement Ndegwa to our senior management team. He has extensive experience working in-house for some of the largest banks in the industry. In addition to his considerable legal expertise and institutional insight, he has a prior proven ability to coordinate interdepartmental initiatives and serve as an executive advisor. In this fast-paced regulatory environment, having such a strong player on our team is a big advantage.”

About NCB Management Services Inc.

NCB Management Services, Inc., established in 1994, is headquartered in the Philadelphia area with satellite offices in Jacksonville, FL, Lincoln, NE, and Sioux Falls, SD. NCB is a recognized Accounts Receivable Management (ARM) industry leader as well as a nationally respected debt buyer. The company is partially owned by its employees through an Employee Stock Ownership Plan (ESOP). The NCB ESOP is a company-funded defined contribution retirement plan established in 2014 for the benefit of NCB employees.

A federal district court just used the phrase “wink wink” in a TCPA class action certification ruling with $100MM at stake. And somehow that isn’t even the weirdest part of the ruling. Read on to learn what happened.

Some company sent some faxes back in 2011. (2011 people. Back then I wasn’t even the only one using a blackberry.) The Plaintiff claimed the faxes were sent without consent. There were over 200,000 faxes sent — which, using the TCPA’s statutory damages, means that Defendant is staring at over $100,000,000.00 in minimum statutory damages.

[article_ad]

Of course, the case can never be certified since Plaintiff would have to prove that the faxes were sent without consent across the entire class using common evidence, which it could never do.

Just kidding.

Instead, the Court impermissibly put the burden of proving consent on the Defendant. When the Defendant seemingly met that burden — albeit meekly — the Court summarily disregarded it and certified the case anyway. Why? In Vandenberg & Sons Furniture, Inc. v. Alliance Funding Grp., Case No. 1:15-CV-1255, 2021 U.S. Dist. LEXIS 11970 (W.D. Mich.  January 22, 2021), the Court found that the Defendant had not explained where the fax numbers at issue had come from or convincingly demonstrated the existence of a written policy. (Importantly, it should have been Plaintiff’s burden to prove that the numbers all came from the same source — not the Defendant’s burden of proving multi-source — but we can discuss that outside the context of this article.)

Here’s the meat of the analysis:

Based on the lack of records, this Court, like the magistrate judge, has difficulty accepting as fact that Alliance had a policy of obtaining consent before sending any fax. Alliance did not send just a few faxes. It paid WestFax over $13,000 to send 465,758 pages. How did Alliance obtain the fax numbers? Where is the company’s written policy? Where are the sales representatives testifying as to following any policy? At the hearing, the Court expressed concern as to why Vandenberg did not depose any sales representative. Vandenberg responded that Alliance did not disclose any such witness. The record contains no evidence as to the number of sales representatives employed by Alliance. Because Alliance has not disclosed any sales representative other than the Vice President of Sales and Sales Manager as a possible witness in discovery, it is unlikely that any sales representative will be permitted to testify for Alliance at trial.

And here’s the “wink wink” part:

Allowing Alliance to defeat class certification based solely on the testimony of two management employees regarding an unwritten policy would create a roadmap for future companies to defeat class certification. In other words, “Send the fax but be sure to destroy all evidence of to whom you sent it.” Or, Alliance may have had such a policy—wink, wink—fully expecting or even encouraging its employees to ignore the policy. This is not to say that Alliance did not have this unwritten policy. But, as of now, the Court finds that whether such a policy existed can be decided at the class level.

(Emphasis added.)

Yep. “Wink wink.”

The Court essentially refuses to credit the Defendant’s evidence at the class certification stage and suggests it could just be making up the fact that they had a policy to seek consent to call the numbers. And while the Court chastises Defendant for failing to come forth with evidence of consent it was actually the Plaintiff that owed the burden to prove an absence of consent can be demonstrated using common evidence. (Don’t let the substantive burden on the issue of consent confuse you—the issue is whether consent can be proven on a classwide basis.)

Now, in fairness, the Court is correct that whether a policy exists to obtain consent can be proven on a classwide basis—but whether the policy was violated with respect to specific faxes cannot be and that is the point. By failing to credit the existence of a policy to begin with, however, the Court has essentially created an assumption of guilt that enabled certification of a case that should not have been certifiable.

And all of this over faxes from 2011. And with $100MM on the line.

Eesh.

Takeaways here:

1. Unlike love, TCPA violations are forever (J/K—love is forever too);
2. Have a written TCPA policy. No seriously, have one.
3. Don’t send faxes.
4. Don’t send 100s of thousands of faxes.
5. Have a written TCPA policy.
6. Always assume that the court will (improperly but commonly) impose a burden on a TCPA defendant to prove consent, even though it really shouldn’t do that;
7. Do not assume that a court will credit perfectly admissible and uncontradicted evidence about an unwritten TCPA policy;
8. Have a written TCPA policy.
9. $100MM is a lot of money.
10. 2011 was a long time ago.
11. Have a written TCPA policy.

JACKSONVILLE, Fla. — Imagined.Cloud and LegalStream are excited to announce that they have joined forces to deliver a platform that seamlessly manages legal account outsourcing. 

Imagined.Cloud and LegalStream are now integrated to provide a seamless interface for the lifecycle management of outsourced legal accounts. The integrated platforms provide end-to-end visibility, transparency and complete reconciliation of all legal accounts placed with law firms. Within Imagined.Cloud’s OutSourcer® solution, clients will now be able to manage ALL outsourced accounts inside a single platform.

[article_ad]

Carl Harkleroad, Founder of Imagined.Cloud, said “Our OutSourcer® solution provides administrative ease and unparalleled insight for managing first and third-party agencies. We needed more depth for the attorney placements and the LegalStream platform elevates the legal outsourcing process significantly. We are excited that our clients can seamlessly utilize Legal Stream from our native Cloud platform”. 

Dan Rabin, President of LegalStream, believes that integration with Imagined.Cloud provides a unique opportunity for customers to have visibility to all their accounts, no matter the collection strategy employed.  “It has been our experience that the placement of legal accounts with all their nuances, and the subsequent data exchanges has been a challenge for some of our clients.  That is why we are excited about being integrated with Imagined.Cloud”.

About Imagined.Cloud 

Founded in 2016, Imagined.Cloud is focused on cloud native application development for debt collections, recovery and business process outsourcing.  Established to bridge the gap between traditional business processes and a secure cloud architecture. Imagined.Cloud’s first solution, OutSourcer®, provides fluid outsourcing process management with real-time compliance and activity monitoring to ensure compliance adherence. For more information or to schedule a demo, visit https://www.imagined.cloud or call 877.787.0730.

About LegalStream, Berman & Rabin 

Berman & Rabin is a nationally recognized comprehensive payment solutions provider to perform pre-charge and post-charge off collections. In addition, Berman & Rabin, in conjunction Legal Stream, a wholly owned subsidiary, can perform a full spectrum of litigation services, including dormant judgments and replevins, nationwide, thus offering you a true one-stop-shop. We offer top tier and comprehensive suite of reports that provides visibility of performance and the status of every account that are available on demand. Our expertise includes consumer credit cards, mortgage, commercial lending, auto, healthcare, installment and revolving loans, customer care programs, as well as customized projects. To learn more visit https://www.br-ls.com

The Maryland Commissioner of Financial Regulation issued an emergency regulation on January 22 putting procedures into place for remote work for employees of state-regulated entities — including debt collectors. The regulation is scheduled to be published on January 29 and is valid for 6 months while the regulator begins the public comment process of a proposed final regulation. 

The regulator recognized the unique need for remote work as a result of the COVID-19 pandemic and, at the same time, balancing it with the need of continued protecting consumers. Due to this, the regulation includes several requirements, including rules around:

1. Employee location. For example, the location cannot receive mail or physical payments (such as cash or checks) and cannot be used for document storage. The location must also provide a workspace that is secure in order to protect the personal information of consumers. 
2. Security requirements. These include monitoring the security program to ensure it is functioning properly. There is also a section that discusses procedures in the event that a data breach occurs.
3. Employee Supervision.  Including the requirement to terminate the employee’s permission to work from home if the regulator determines that the licensee does not have sufficient supervision of the employee.

[article_ad]

insideARM Perspective

This is an excellent step forward by Maryland’s regulators. COVID-19 pushed many employers — including those within the industry — to allow remote work for their employees, and it seems like remote work is here to stay in some form or another. The work undertaken by Maryland’s regulators to both recognize this trend and create a workable solution is great news, and hopefully, other states follow it.

The Consumer Relations Consortium (CRC) played a pivotal role in proposing a framework that state regulators could use as a strawman to think through this regulation. Stephanie Eidelman, Executive Director of the CRC said, “We are proud of our role in this example of government and industry working together to develop reasonable and practical regulation.”

As we have reported, the FCC’s recent ruling implementing Section 8 of the TRACED Act was a really big deal: it limited the number of calls permitted under certain extremely-valuable and important exemptions related to prerecorded calls to landlines. But it turns out that the ruling may have actually done much more, albeit likely by accident.

Here is the issue: 47 C.F.R. § 64.1200(a)(3) previously provided that “[n]o person or entity may… [i]nitiate any telephone call to any residential line using an artificial or prerecorded voice to deliver a message without the prior express written consent of the called party.” Exempted from this requirement were, inter alia, all calls made for a commercial purpose that did not include marketing content, all non-commercial calls, all HIPPA calls, etc.

[article_ad]

Since these were wholesale exemptions, the section required written consent to place any non-exempt calls. Marketing calls were the only thing left within its gambit. Because the exceptions to 64.1200(a)(3) were so broad that they basically covered everything but marketing calls, the restriction was drawn very narrowly and required the highest level of consent.

Well, when the FCC implemented its new call limitations it limited the exemptions of 64.1200(a)(3) without addressing the express written consent requirement–that was presumably never intended to apply to non-marketing calls. So the new reg will read:

[Thou shalt not:]

(3) Initiate any telephone call to any residential line using an artificial or prerecorded voice to deliver a message without the prior express written consent of the called party, unless the call;

(i) Is made for emergency purposes;

(ii) Is not made for a commercial purpose and the caller makes no more than three calls within any consecutive 30-day period to the residential line and honors the called party’s request to opt out of future calls as required in paragraphs (b) and (d) of this section;

(iii) Is made for a commercial purpose but does not include or introduce an advertisement or constitute telemarketing and the caller makes no more than three calls within any consecutive 30-day period to the residential line and honors the called party’s request to opt out of future calls as required in paragraphs (b) and (d) of this section;

(iv) Is made by or on behalf of a tax-exempt nonprofit organization and the caller makes no more than three calls within any consecutive 30-day period to the residential line and honors the called party’s request to opt out of future calls as required in paragraphs (b) and (d) of this section; or

(v) Delivers a “health care” message made by, or on behalf of, a “covered entity” or its “business associate,” as those terms are defined in the HIPAA Privacy Rule, 45 CFR 160.103 and the caller makes no more than one call per day to each patient’s residential line, up to a maximum of three calls combined per week to each patient’s residential line and honors the called party’s request to opt out of future calls as required in paragraphs (b) and (d) of this section.

(Emphasis added.)

So what’s the big deal?

Under the TCPA calls delivering informational content generally only require express consent, not express written consent. Thus, collection calls to cell phones can be made with mere presumed express consent anytime a number is provided by the debtor to the creditor absent contrary instructions.

But the implication — again, apparently unintended — of the CFR edit, is that a different rule will apply to pre-recorded calls (including avatar/soundboard) to landlines. In that context, the caller will need to have WRITTEN consent to make even INFORMATIONAL calls to landlines using a pre-recorded voice message after the call limits imposed by the Commission are exceeded.

Previously, of course, such calls required no consent at all, but callers presumably expected to be able to make “extra” calls with regular old “prior express consent” as the FCC’s order implied. E.g. ruling at par 20 (“In addition, as discussed above, callers can make more than three non-commercial calls using an artificial or prerecorded voice message within any consecutive 30-day period by obtaining the prior express consent from the called party, including by using an exempted call to obtain consent.”)

Obviously, you can’t use an exempted call to obtain written consent, unless the recording of a call constitutes a written agreement, but it doesn’t. Probably. (That’s an entirely separate can of crunchy worms.) The point is the FCC’s order plainly appears to assume that regular express consent will work for informational calls exceeding the call limit– but that is not what the CFR edits are going to say.

I have it on good authority that a few trade groups are dreaming up a fix to this issue — if it even is an issue — but in the short term callers would be well advised to take a note here:

JUST BECAUSE YOU HAVE EXPRESS CONSENT THAT MAY NOT BE SUFFICIENT TO PERMIT PRERECORDED CALLS TO LANDLINES FOR INFORMATIONAL (INCLUDING DEBT COLLECTION) PURPOSES ONCE THE NEW CFR LANGUAGE IS EFFECTIVE. INSTEAD YOU MAY NEED TO LIMIT YOURSELF TO 3 CALLS PER MONTH OR OBTAIN WRITTEN CONSENT.

And yes, there is a private right of action here.

CHERRY HILL, N.J. — MRS is pleased to announce that Kelly Feoli has been promoted to Executive Vice President of Operations, assuming responsibility for all third party operations as well as overseeing the Training Department and joining MRS’s Executive team.. 

Feoli joined MRS in 2010 as an agent, with no previous experience in the collection industry. For several years, she was a top performer, earning every operational achievement available at MRS before being promoted to manager. She quickly took on more responsibility in the third party operations division, driving best-in-class results and was promoted several times. 

“In our 30 years, Kelly is MRS’s best homegrown success story. Hired as an inexperienced agent a decade ago, and working her way to the Executive team is a testament to her work effort, dedication, strategic thinking and leadership, which are felt throughout the company,” said Co-CEO Saul Freedman. 

In this role, Feoli is responsible for the third party operational results of three facilities across several dozen clients in financial services, student lending, auto deficiencies, telecommunications, cable and municipal industries. 

COO Jim Beck said, “Kelly has contributed to our company and success for our clients in so many ways and I am looking forward to seeing her increase her impact across the entire organization.  Kelly’s input and perspective is going to be a valuable contribution to the Executive team at MRS.”

“MRS has made it really easy for me to flourish.  They provided me with the tools, guidance and vision to become a leader and I can’t wait to make a difference as part of the Executive team,” remarked Feoli.